Italy - An Update on the Concept of Beneficial Ownership from an Italian Perspective
- L. Banfi; F. Mantegazza
- European Taxation, 2012 (Volume 52), No 2/3
- 27 January 2012
This article provides an overview of the concept of beneficial ownership from an Italian perspective based on the Italian tax law framework and in light of guidance provided by the Italian tax authorities, as well as case law. The article also sheds light on recently enacted provisions that could mitigate beneficial ownership issues arising in connection with certain intra-group financing structures involving Italian companies and EU associated companies.